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  • Computer Forensics for IP Lawyers (RECORDING)

    Contains 3 Component(s)

    This webinar will be a high-level, introductory guide to computer forensics for IP lawyers.


    Speakers:

           Cathleen Donohoe, Pillsbury

           David Freskos, FTI Consulting

           Shannon Murphy, Winston & Strawn


    Cathleen Donohoe

    Pillsbury

    Cathleen Donohoe is an attorney in the Silicon Valley office of Pillsbury. She focuses her practice on cybersecurity, corporate investigations, and complex commercial litigation. She has successfully conducted and resolved numerous internal investigations for company boards of directors and committees involving breaches of contract and IP misappropriation.

    David Freskos

    FTI Consulting

    David Freskos is a senior director at FTI Consulting. He provides expert computer forensic and e-discovery consulting services to legal teams in support of investigations and litigation. David specializes in complex data collections from mobile devices, social media and cloud-based storage.

    Shannon Murphy

    Winston & Strawn LLP

    Shannon Murphy is a partner at Winston & Strawn. She is member of the firm’s Global Privacy and Data Security Task Force and focuses her practice on internal investigations, data protection counseling, and complex litigation, particularly matters involving potential criminal liability or trade secret issues. She is a specialist in computer forensics, and her data protection experience includes conducting a large-scale trade secrets internal investigation for a privately held financial investment company, which led to the federal conviction of two employees and a significant judgment.

     

  • Reasonable Measures to Protect Trade Secrets: Lessons for Litigators and In-House Counsel (RECORDING)

    Contains 3 Component(s) Recorded On: 05/30/2019

    Reasonable Measures to Protect Trade Secrets: Lessons for Litigators and In-House Counsel

    Speakers:

    Kenneth Corsello, IBM

    David Morrison, Goldberg Kohn

    Shannon Murphy, Winston & Strawn LLP

    Kenneth Corsello

    IBM

    David Morrison

    Goldberg Kohn

    Shannon Murphy

    Winston & Strawn LLP

    Shannon Murphy is a partner at Winston & Strawn. She is member of the firm’s Global Privacy and Data Security Task Force and focuses her practice on internal investigations, data protection counseling, and complex litigation, particularly matters involving potential criminal liability or trade secret issues. She is a specialist in computer forensics, and her data protection experience includes conducting a large-scale trade secrets internal investigation for a privately held financial investment company, which led to the federal conviction of two employees and a significant judgment.

     

  • PTAB Discretion: Exploring the New Metes and Boundaries (RECORDING)

    Contains 3 Component(s) Recorded On: 05/23/2019

    This webinar will explore the scope and impact of recent important PTAB precedential opinions, as well as the decisions that have been designated “informative.”

    The PTAB has issued a large number of precedential decisions in the last few months, following the Board’s issuance of its Revised Standard Operating Procedure 2 (“SOP2”) in September 2018.  Just this month, the newly established Precedential Opinion Panel designated as precedential two additional IPR decisions: Valve Corp. v. Elec. Scripting Prods., Inc. and NHK Spring Co., Ltd. v. Intri­-Plex Techs., Inc.

    Many of these recent precedential decisions articulate how the PTAB will use its discretion as granted in AIA sections 314, 315, and 325, and are therefore of key concern to petitioners, patent owners, and their counsel.  

    This webinar features a Vice Chief Administrative Patent Judge of the PTAB, an in-house counsel, and a litigator. They will explore the scope and impact of recent important PTAB precedential opinions, as well as the decisions that have been designated “informative.” 

    Topics to be discussed include:

    • Now binding cases regarding follow-on petitions, where the same patent is challenged multiple times by the same petitioner or by a series of petitioners
    • PTAB discretion regarding first-filed petitions
    • Same party issue joinder and real-party-in-interest issues as articulated in two cases named Proppant Express Investments, LLC v. Oren Techs., LLC
    • PTAB discretion to deny institution
    • Details on SOP2 changes to procedures

    Speakers:  

    • Orion Armon, Cooley LLP
    • Kirby Lee, Ecolab
    • Vice Chief Judge Scott Weidenfeller, U.S. Patent and Trademark Office

    Orion Armon

    Cooley LLP

     is a partner at Cooley LLP. He is a trial lawyer who focuses on multi-venue, complex patent litigation matters in district courts and before the PTAB and the U.S. Court of Appeals for the Federal Circuit. He has particular experience utilizing inter partes review in combination with district court litigation strategies. As lead counsel for Enfish, Orion argued the appeal in Enfish v. Microsoft Corp. (Fed. Cir. 2016). He is a member of IPO’s U.S. Post-Grant Patent Office Practice Committee.

    Kirby Lee

    Ecolab

     is assistant chief IP counsel at Ecolab, a global leader in water, hygiene, and energy technologies and services.  Kirby previously worked at the Department of Justice and the White House, representing the U.S. government in intellectual property litigation and serving as a senior policy advisor to the IP Enforcement Coordinator. HHeHHe also served as a clerk to the Hon. Alan Lourie of the Federal Circuit. Kirby is co-chair of the IPO litigation committee.

    Vice Chief Judge Scott Weidenfeller

    U.S. Patent and Trademark Office

     is Vice Chief Administrative Patent Judge of the Patent Trial and Appeal Board. He manages operational and administrative aspects of the Board, including providing guidance on legal issues and the impact of changes to internal Board procedures. He previously served as Associate Solicitor of the USPTO. His primary responsibilities included managing litigation against the USPTO involving the AIA, including challenges to PTAB post-issuance proceedings. Before joining the USPTO, he worked in private practice and served as a law clerk to the Hon. Timothy B. Dyk of the Federal Circuit.



  • AI: Protecting Inventions in China, Europe and the U.S. (RECORDING)

    Contains 7 Component(s), up to 1.00 CLE credit hours

    This webinar will address how to approach the challenge of obtaining AI patent protection in three major jurisdictions, as well considering when the alternative of trade secret protection could be a better course to take.

    Artificial intelligence (AI) is attracting massive investment and AI systems seem certain to become further embedded in many industries, as well as into daily life around the world. How to best protect these inventions is a complicated issue that is playing out differently around the globe.

    This webinar will address how to approach the challenge of obtaining AI patent protection in three major jurisdictions, as well considering when the alternative of trade secret protection could be a better course to take.  Various litigation scenarios will also be considered, including the ongoing dispute in China between Zhizhen Network Technology and Apple that relates to Apple's Siri voice assistant app.

    Protecting AI inventions is not easy even when inventors and prosecutors only focus on just one set of national requirements. Experts say that to write an AI patent application it is useful to know the basics of feature engineering, gradient-descent training, genetic-algorithm training, and multi-batch techniques for organizing training data. Patents must be prepared taking into consideration both the possibility of infringement being difficult to detect ‒ and who will be considered the infringer. With AI inventions, there might be more players involved than you expect.

    Our panelists include in-house AI patent experts (one at a Chinese tech company and the other at a U.S. tech company), as well as an experienced German patent prosecutor. They will, among other things, use claim sets for actual AI inventions to compare and contrast patent law and practice among the three jurisdictions in two key areas for AI:

    • Patent eligibility, including the impact of the new USPTO guidelines put forth in January, and
    • Written description, enablement, and functional claiming.

    Speakers:  

    • Jessica Meyers, Microsoft
    • Andreas Holzwarth-Rochford, Jones Day
    • Roger Shang, Alibaba


    Andreas Holzworth-Rochford

    Jones Day

    is a partner in the Frankfurt office of Jones Day. He has prosecuted numerous IP applications and has been involved in litigation in the areas of physics and mechanical and electrical engineering. Andreas has significant technical experience in optics, laser technology, and software-implemented inventions, especially artificial intelligence and blockchain applications, wireless data communications, network engineering, medical devices, and digital health applications. He is the co-author of “Patenting Artificial Intelligence and Machine Learning Innovations in Europe.

    Jessica Meyers

    Microsoft Corp.

     is a senior patent attorney for Microsoft, specializing in artificial intelligence. She harvests innovations from AI engineering teams, advises AI engineering teams on patent practice, and actively reviews and edits patent applications and Office action responses. She also analyzes Microsoft’s patent portfolio and prepares claim charts for licensing and litigation. Prior to joining Microsoft, Jessica was a patent portfolio manager at the University of Washington Center for Commercialization and a patent attorney at Perkins Coie.

    Roger Shang

    Alibaba

    is Senior Legal Director at Alibaba Group.  He joined Alibaba in 2008 as its first chief patent and technology counsel and oversaw the development of its global patent program.  He also founded the legal department for Alibaba Cloud Computing.  Roger now works on international patent portfolio development, IP licensing, technology collaboration, open source, and NPE defense matters.  Prior to joining Alibaba, Roger practiced patent law at Weil Gotshal and Knobbe Martens.

  • IPR Estoppel One Year After SAS (RECORDING)

    Contains 6 Component(s), up to 1.00 CLE credit hours

    This webinar will address how district courts have applied IPR estoppel in the year since SAS was decided

    In SAS v. Iancu, the U.S. Supreme Court required the PTAB to decide the patentability of every claim challenged in a petition for inter partes review. SAS did not directly address IPR estoppel, but its holding has indirectly broadened this doctrine. This development is now playing itself out in the courts, with significant consequences for all those involved.

    This seminar will address how district courts have applied IPR estoppel in the year since SAS was decided. Panelists will not only highlight recent cases, but will also provide tactics for both plaintiffs and defendants to make arguments about the proper scope of IPR estoppel in district court litigation. This is ever more important because of the large shift in district court fights to a case-by-case analysis to determine what art “reasonably could have been raised.”

    The panel will include the post-grant proceedings director of a major patent owner and two law firm attorneys with vast experience before the PTAB, district courts, and the Federal Circuit. The topics they will address include:

    • SiOnyx v. Hamamatsu Photonics (D. Mass.) and the principle that “after SAS [a narrow view of AIA estoppel] cannot be correct”
    • Oil-Dri Corp. of America v. Nestle Purina Co. (N.D. Ill.) and the increasing importance of on-sale prior art that can be used in district court, but that could not have been raised in the IPR
    • The pending Federal Circuit appeal in BTG International Ltd. et al. v. Amneal Pharmaceuticals LLC et al. and whether the America Invents Act stops patent challengers who won at the PTAB from pursuing their winning arguments in court

    Speakers:  

    • Grantland Drutchas, McDonnell Boehnen Hulbert & Berghoff LLP
    • James Hietala, Intellectual Ventures Management, LLC
    • Eliot Williams, Baker Botts LLP

    Grantland Drutchas

    McDonnell Boehnen Hulbert & Berghoff LLP

    is a founder and current managing partner of McDonnell Boehnen Hulbert & Berghoff LLP. He has more than 20 years of experience in the practice of IP law, with a particular emphasis on litigation, licensing, and client counseling. Grant serves as chair of the firm’s PTAB Trials Practice Group, its Licensing Practice Group, and its Litigation & Appeals Practice Group. His experience includes both jury and bench trials, as well as arguing before the U.S. Court of Appeals for the Federal Circuit.  He is a vice chair of IPO’s Pharmaceutical and Biotechnology Issues committee.

    James Hietala

    Intellectual Ventures Management LLC

    is director of post-grant proceedings at Intellectual Ventures Management LLC. He has, at times, managed 30 simultaneous cases at the PTAB. He also plays an influential role at his company in setting the strategic direction on post-grant (IPR, CBM, and reexam) proceedings involving mechanical and electrical technology. Previously, James worked in private practice. He is a member of the IPO Post-Grant Patent Office Practice committee.

    Eliot Williams

    Baker Botts LLP

    is co-chair of the PTAB practice at Baker Botts.  He has represented clients in many CBMs and IPRs, as well as in district court. He has appeared as counsel in more than 100 PTAB trials, making him one of the most experienced PTAB litigators nationwide.

  • Disqualification: Lessons from Recent Cases (RECORDING)

    Contains 5 Component(s), up to 1.00 CLE credit hours

    This webinar will discuss responsibility decisions as well as the approaches taken by courts when considering disqualification of counsel

    CLE NOTICE: IPO will apply for Ethics credit for this webinar. Please note that not all states will approve for Ethics credit.

    Conflicts of interest in litigation settings plague law firms and their clients, spurred by long term trends such as the advent of megafirms, the proliferation of corporate subsidiaries, and acquisitions.  It is thought that most difficult disputes never become public.  But disqualification proceedings in courtrooms are far from rare.  This webinar will extract lessons for both law firms and their corporate clients on how to try to avoid this minefield, including by analyzing recent disqualification fights in both state and federal courts. 

    In addition to the professional responsibility issues that are implicated, the economic consequences of disqualification loom large.  Law firms can suffer damage to their reputation just by being the target of a disqualification proceeding.  In addition, disqualification can be financially costly.

    This seminar will look at professional responsibility decisions, as well as the approaches taken by courts when considering disqualification of counsel.  It will discuss whether court disqualification will generally occur solely because of an ethical violation — or whether the totality of the circumstances will be analyzed.

    Our panel includes a senior litigation counsel at a major tech company, the general counsel of a large international law firm, and an attorney who specializes in legal professional responsibility and ethics.  They will analyze recent cases with conflicts issues, including those relating to:

    • Corporate affiliations
    • Advance conflict waivers
    • Marketing conversations with prospective clients
    • Lateral hires
    • The hot potato doctrine


    Speakers:  

    • William Freivogel, Independent Consultant
    • Martin Kaminsky, Greenberg Traurig LLP
    • Deanna Kwong, Hewlett Packard Enterprise

    Martin Kaminsky

    Greenberg Traurig LLP

    serves as the general counsel of Greenberg Traurig, an international law firm with a large IP litigation practice.  Previously, Marty represented clients that included public companies, exchanges, and professional services firms and their principals in litigation, including professional responsibility matters.  He is author of “Legal and Ethical Issues Involved in Representing Affiliates or Principals of Clients.”

    Deanna Kwong

    Hewlett Packard Enterprise

    is senior IP litigation counsel within the Office of Legal and Administrative Affairs at Hewlett Packard Enterprise Company (HPE).  She and the HPE IP litigation team are responsible for managing all IP lawsuits that are filed against or by HPE worldwide.  Prior to joining HPE, Deanna was in private practice for over a decade.  Deanna serves on the IPO Damages Committee.

    Michael McCabe

    mike@ipethicslaw.com

    Michael McCabe of McCabe Law LLC represents patent and trademark attorneys, registered patent agents, and other IP professionals in matters concerning ethics, discipline, and professional responsibility. His practice includes matters before the USPTO’s Office of Enrollment and Discipline and the state bars of Maryland, Virginia, and the District of Columbia.  He is a registered patent attorney and previously was a litigation partner at two large firms.

  • Standing to Appeal from the PTAB (RECORDING)

    Contains 5 Component(s), up to 1.00 CLE credit hours Recorded On: 04/04/2019

    This webinar will answer questions about the rapidly evolving case law regarding this issue which, years after the passage of the AIA, remains partially unresolved.

    Who can appeal an inter partes review?  This webinar will answer questions about the rapidly evolving case law regarding this issue which, years after the passage of the AIA, remains partially unresolved.  Our panel of experts will also address strategies for obtaining, and opposing, appellate standing.

    This year the Federal Circuit has already addressed standing on three occasions: Mylan v. Research Corp. TechnologiesMomenta v. Bristol-Myers, and Amerigen v. UCB.  Cases appear to fall along a spectrum, with one end including cases where it appears clear that petitioners who were unsuccessful will not have standing and, on the other end, cases where it appears they surely will.  Many interesting cases fall in a complicated middle ground, and a number of those involve products that require a long and expensive development process, such as pharmaceuticals, biosimilars, or aircraft engines. For petitioners in those matters trying to establish appellate standing, the challenge of showing real and immediate injury in fact can difficult to navigate.

    In addition to lessons learned from recent cases, our panelists will discuss:

    • The argument that injury from IPR estoppel in future district court litigation, after a losing challenge, is enough to create standing
    • The theory that standing is created after an unsuccessful challenge because a patent impedes research
    • Other strategies for making the case for and against standing
    • The recently argued U.S. Supreme Court case of Return Mail
    • The Court’s request for the Solicitor General’s views regarding the pending petition for writ of certiorari in RPX Corp. v. ChanBond LLC
    • Procedural details for appeals related to standing

    Speakers:  

    • Neal Dahiya, Bristol-Myers Squibb Company
    • Michael Flibbert, Finnegan, Henderson, Farabow, Garrett & Dunner, LLP
    • Steven Parmelee, Wilson Sonsini Goodrich & Rosati

    Neal Dahiya

    Bristol-Myers Squibb Company

    is an assistant general counsel at Bristol-Myers Squibb, handling global patent litigations as well as business development for the IP group. Prior to joining BMS in 2012, Neal was in private practice for nine years at major law firms in New York.

    Michael Flibbert

    Finnegan, Henderson, Farabow, Garrett & Dunner, LLP

    is a partner at Finnegan, Henderson, Farabow, Garrett & Dunner, LLP. As a patent litigator, Mike serves as lead counsel in inter partes review (IPR) proceedings before the PTAB, district court litigations, and Federal Circuit appeals. He served as lead counsel in a successful recent Federal Circuit appeal from an IPR proceeding, resulting in reversal of the PTAB’s decision and invalidation of all challenged claims. Mike also served as a law clerk to the Honorable Alan Lourie of the Federal Circuit.

    Steve Parmelee

    Wilson Sonsini Goodrich & Rosati

    is of counsel at Wilson Sonsini Goodrich and Rosati.  Steve is a member of the firm’s post-grant review practice representing clients before the PTAB.  Previously, Steve was managing partner of the Seattle office of Townsend & Townsend and an in-house counsel at two pharma companies.  Steve has represented both petitioners and patent owners before the Board, and in related appeals to the Federal Circuit.  He recently represented a client in an appeal of an IPR in which the Federal Circuit clarified the rights of parties joined to a petition.

  • SEPs and the Autos: Lessons for the Internet of Things (RECORDING)

    Contains 4 Component(s), up to 1.00 CLE credit hours

    This webinar will discuss the importance and evolving legal concepts that inform negotiations in this area, as well practical ideas for improving approaches to licensing discussions

    As cars quickly adopt improved connectivity, SEP owners and those in auto-related industries find themselves at the center of new developments in technology and the law.  5G SEP owners and automakers are experiencing a unique collision in business and IP cultures.  The lessons that emerge will be useful for other industries that want to become part of the Internet of Things (IOT).

    Our panel includes the senior vice president of a patent pool of SEP owners geared to autos and the IOT, the director of IP at the leading ride-sharing company, and a law professor who specializes in standards.  They will focus on important and evolving legal concepts that inform negotiations in this area, as well practical ideas for improving approaches to licensing discussions.  Among the topics to be discussed:

    • Can SEP owners vary royalties based on device characteristics, or the level in the distribution chain, and remain compliant with FRAND?
    • How to establish a FRAND royalty in a new market with no comparable licenses
    • The strengths and weaknesses of patent pool solutions
    • The possible use of third-party experts to opine on the essentiality of patents included in standards
    • How negotiation issues between SEP owners and carmakers differ from issues involving smartphones
    • Other lessons applicable to the IOT


    Speakers:  

    • Jorge Contreras, University of Utah School of Law
    • Bill Harmon, Uber
    • Luke McLeroy, Avanci

  • Patent Term: The Impact of Recent Cases for Addressing Insights for Prosecution and Litigation (RECORDING)

    Contains 5 Component(s), up to 1.00 CLE credit hours

    This webinar will help patent owners and their counsel navigate both patent prosecution and litigation issues related to patent term.

    This webinar will help patent owners and their counsel navigate both patent prosecution and litigation issues related to patent term by drawing on insights from three recent Federal Circuit decisions: Novartis AG v. Ezra Ventures LLC, Novartis Pharmaceuticals Corp. v. Breckenridge Pharmaceutical, and Supernus Pharmaceuticals, Inc. v. Iancu. Some commentators believe that these decisions give patent owners a chance to obtain potentially lucrative extensions of patent term, and that they have reined in the scope of obvious-type double-patenting.

    Ezra addresses what happens when one patent expires later than another related patent due to a patent term extension. Breckenridge deals with a scenario where one patent filed earlier expires later than another due to a 1995 law that changed the length of patent terms. Supernus limited the USPTO’s ability to reduce patent term adjustment (PTA) based on delays in prosecution.

    Our panel has vast experience with issues relating to PTA and patent term extension (PTE). It includes an in-house counsel at a medical device manufacturer, a patent prosecutor in biotech and pharma, and a life science patent litigator who represents both innovator and challenger entities. They will discuss:

    • Strategies for obtaining PTA/PTE at the USPTO, including deciding which of multiple patents covering a product are best suited for PTE
    • How to try to avoid terminal disclaimers
    • Options for applicants with pending patent applications
    • The remaining threat of double-patenting challenges in litigation


    Speakers:  

    • Jack Brennan, Fish & Richardson, P.C.
    • Jeff Hohenshell, Medtronic, Inc.
    • Nicholas Mitrokostas, Goodwin Procter, LLP

    Jack Brennan

    Fish & Richardson, P.C.

    Jack Brennan is a principal in the New York office of Fish & Richardson P.C.  His practice emphasizes patent prosecution, opinions, due diligence, and client counseling in the fields of biotechnology and pharmaceuticals.  Several years ago, Jack successfully challenged the way the U.S. Patent and Trademark Office calculates Patent Term Adjustment for patents resulting from national stage filings under 35 U.S.C. 371.  He holds a Ph.D. in genetics.

    Jeffrey Hohenshell

    Medtronic, Inc.

    is a senior patent attorney at Medtronic. An experienced patent prosecutor and strategist, he has had success invalidating for double patenting several patents covering patient-monitoring systems that were asserted against Medtronic.

    Nicholas Mitrokostas

    Goodwin Procter LLP

    is a patent litigator and partner in Goodwin Procter’s IP Litigation group.  Nick has extensive trial and PTAB experience representing clients in the pharmaceutical and biotechnology industries in patent and antitrust litigation.  He represents both innovator and challenger entities, is an editor of the Biosimilars Reference Guide, and co-leads a biosimilars blog, www.bigmoleculewatch.com.

  • Strategies for Addressing Patent Venue Issues (RECORDING)

    Contains 5 Component(s), up to 1.00 CLE credit hours Recorded On: 02/28/2019

    This webinar will discuss important Federal Circuit decisions since TC Heartland regarding venue.

    Patent venue issues continue to be the subject of much interest ‒ and litigation. This webinar will look at important Federal Circuit decisions since TC Heartland regarding venue. The panel will also give tactical tips regarding still open questions — and common battles in district courts.

    Most recently, earlier this month, the Federal Circuit refused to rehear en banc Google’s petition for a writ of mandamus that contested a decision in the Eastern District of Texas that had found venue based upon the fact that Google servers are housed in third-party facilities in the district.  The dissenting opinion stated, however, that there is “growing uncertainty among district courts and litigants as to the requirements of § 1400(b) when conducting business virtually through servers and similar equipment...”

    Our panel will not only review recent cases, but will provide insights on strategies to address venue issues.  It includes an in-house counsel who has overseen a lengthy venue fight, a litigator who won a Federal Circuit case creating new law on venue, and an expert on Federal Circuit practice and policy.  Among the subjects they will discuss are:

    • Considerations for defendants when weighing the risks of a potentially unfriendly venue vs. the cost of challenging venue
    • Conflicting district court fact-­intensive decisions over the § 1400(b) “regular and established place of business” inquiry
    • How best to approach open issues such as waiver and time period in determining venue


    Speakers:  

    • John Dragseth, Fish & Richardson, P.C.
    • Eileen Hunter, 3M Innovative Properties Co.
    • Charlie McMahon, McDermott Will & Emery

    Jack Brennan

    Fish & Richardson, P.C.

    Jack Brennan is a principal in the New York office of Fish & Richardson P.C.  His practice emphasizes patent prosecution, opinions, due diligence, and client counseling in the fields of biotechnology and pharmaceuticals.  Several years ago, Jack successfully challenged the way the U.S. Patent and Trademark Office calculates Patent Term Adjustment for patents resulting from national stage filings under 35 U.S.C. 371.  He holds a Ph.D. in genetics.

    Eileen Hunter

    3M Innovative Properties Co.

    is Senior IP Counsel at 3M. She manages IP disputes globally, which include patent litigation venue disputes within the U.S. She also serves on 3M’s Global Trade Secret Protection Program task force. Eileen was a Partner at Faegre Baker Daniels and clerked for the Eighth Circuit Court of Appeals. She is a vice chair of IPO’s Litigation Committee.

    Charlie McMahon

    McDermott Will & Emery

    is a Partner at McDermott Will & Emery. His practice focuses on IP litigation. He successfully convinced the Federal Circuit to vacate an Eastern District of Texas ruling that ZTE, which had had contracted with a call center in Plano, Texas, could be sued in the district. In that case, the Federal Circuit clarified that, upon motion by the defendant challenging venue in a patent case, the plaintiff bore the burden of establishing proper venue.